Permitting & Enforcement Committee Meeting March 12, 2013
Permitting and Enforcement Committee FINAL
When: March 12, 2013 Answer Place ID: 2140
9:30 a.m. - 1:00 p.m.
Where: Central Office, Columbus
Conference Room C
Facilitator: Sean Vadas
Minutes: Jenny Avellana
Time / Topic / Lead /Involvement / Actions Needed /
9:30
10:00 / Enforcement/Compliance
New items?
Noncompliance issues with 21-28 / Paulian/Bergman/Weinberg
Akron / General discussion.
See Note #1.
10:00
10:30 / Permitting
New items?
Relocating PBR Sources
Use of powder coatings in 21-09(U) calculations
New MACT Coordinator / Hopkins
Hopkins
RAPCA
Briana Hilton / General discussion.
See Note #2.
See Note #3.
Introduction & Need field office contact names.
10:30
11:00 / Permit Issuance and Data Management
New items? / Ahern / General update.
11:00
11:15 / Break / everyone / Relax & Stretch
11:15
11:30 / New Rules and SIP Update
New items? -No Changes / Paul Braun / General update.
11:30
11:45 / Terms and Conditions and Policy Distribution
New items? / Cheryl / General update.
11:45
12:00 / Engineering Guide Revisions
#6 - PTI for Coal to Oil Conversion / Cleveland/Misty Parsons / Cleveland indicates they cannot revise the guide. Misty will handle the revisions.
#8 – Compliance Tests at Bulk Gasoline Terminals / CDO / Final recommendation submitted to Bruce for final review on 07/23/2012.
#18 - SO2 Compliance Determination Methods for Boilers / Toledo / Bruce reviewing final recommendation.
#20 - Determination of Compliance with Visible Emission Limitations for Stack Source / Akron / Final recommendation submitted to Bruce for final review on 05/09/2012.
#23 - Determination of Significant Figures for TSP Emission Limitations / SEDO / Comments received and making revisions.
#24 - Application of Fugitive Dust Requirements to Affected Facilities / Toledo / Final recommendation submitted to Bruce for final review on 08/14/2012.
#26 - Inclusion of Weight of Water in the Weight of "Refuse" Charged for Incinerators / NEDO / Bruce reviewing final recommendation.
#29 - Applicability of the PTI Rules to Increases in Capacity of a Derated Boiler / CDO / update on progress
#38 - Use of Exempt Organic Compounds to Satisfy BAT Requirements / Akron / Beginning initial review – new selection
#44 - Permit Issuance Policy for Relocation of Portable/Mobile Facilities / CO/SEDO / Erica and Sarah Harter working on changes. – On Hold until rules/forms changed.
#45 - Calculation of "Potential to Emit" for Surface Coating Lines / Canton / update on progress – reviewing guide
#48 - VOC Compliance Determinations for Coating Lines / Canton / update on progress – reviewing guide
#51 - Number of Sampling Runs to be Witnessed by Agency Observers / RAPCA / reviewing guide – recommendation to revoke guide is a possibility
#53 - Interpretation of Open Burning Standards / Paul Braun / update on progress – reviewing guide
#55 - Precautions in Use of Method 24 for Water-Based Coatings / Akron / Final recommendation submitted to Bruce for final review on 09/24/2012.
#69 – Guidance on Air Dispersion Modeling / VanderWielen / Sarah asked for input in revising EG during 2012 annual DAPC workshop.
#70 - Guidance on Evaluating Emissions of Toxic Air Pollution Compounds when Processing Permit-to-Install (PTI) Applications. / Hopkins / Hopkins review comments.
#74 – Stack testing for PM2.5 / Hall / On hold until asphalt plant testing issues are resolved.
#77 - Proper application of amended OAC rule 3745-21-07 / CDO / CDO collecting examples to determine how different situations should be handled when addressing BAT limits that may have come from the old 21-07(G). Possibly add more examples to E.G 77.
#80 – Methods for Calculating PTE / CDO / Issued Final 3/02/12 - additional revisions made by CDO on 9/24/12 and forwarded directly to Bruce. 1/29/13 revisions sent from P&E to Bruce, just in case.
#82 – Ultra Low Sulfur Diesel Fuel Permitting / NWDO/CDO / New Guide. Draft distributed for review 3/7/13. Comments until 4/8/13. [Note the improved look/format – let’s try to use this going forward.]
#83 – Asphalt Testing Production Rates / Todd Brown/Alan / Draft out for review. Comments until 11/2/12. –> On hold until asphalt plant testing issues are resolved. Renumbered from 82 to 83.
#XX – Non-road Engines / SEDO / update on progress
12:00
12:15 / General Permit & Permit By Rule development
Create new GPs and PBRs / Crematories - Cleveland / Sarah VanderWielen to work on mercury modeling September 2010.
Shale Oil & Gas / GP being revised to include recent NSPS. Incorporate new proposed facility naming methodology. Draft issued 2/15/13. Includes language for Flowback PBR.
Miscellaneous Metal / Workgroup formed, Rick Carleski lead. Source categories identified. Working through modeling issues.
12:15
12:30 / Training
New training items? / All / Any new training on the horizon?
APTI website has on-line courses. www.apti-learn.com
David Hearne compiled a list of nearby 2013 training opportunities.
12:30
12:45 / New items
Any new items to discuss? / All / New items to discuss?
Pending Action Items / Date Action Completed
1. Update preliminary completeness letter to address site preparation activities allowed under 31-33. / Done – 11/2/12 RAPCA to make a final revision and redistribute letter. – letter out for comments on 3/8/13, comments due by 3/22/13,
2. Dry cleaner general permit revision / Akron to revise necessary documents and submit to Mike and Cheryl for review. – submitted 7/19/12
Next meeting: May 14, 2013
Remaining engineering guides not revised since the 1980s – Need offices to volunteer to revise these:
Guide 39 - Conversion to Exempt Organic Compounds to Create Emission Offsets under the Bubble Concept & PTI / 8/25/1982Guide 40 - Stack Testing Methods for Particulate Emissions from Process Equipment and Incinerators / 11/5/1982
Guide 41 - Stack Testing Methods for Particulate Emissions from Fuel Burning Equipment / 11/5/1982
Guide 42 - Definition of BAT for New Sources / 12/30/1982
Guide 46 - Determination of Cost-Effectiveness for BAT and RACM Evaluations / 12/5/1983
Guide 47 - Application of TSP Emission Limitations to Cyclones at Alfalfa Dehydrating Plants / 11/30/1984
Guide 49 - Particulate Emission Testing During Boiler Soot blowing Operations / 12/17/1985
Guide 54 - Use of Brine for Road Dust Suppression / 1/13/1987
Added Topics:
#1 – Noncompliance with 21-28 - Akron
How should violations of the miscellaneous industrial adhesive and sealant rule be handled? We want to be consistent we have facilities that are not able to comply with this rule without what they are claiming will be major retooling costing them several hundred thousand dollars. The consultant is shopping for answers or excuses through the OEPA Central Office and even other states.
We have held back pursuing enforcement with a particular facility based on its ongoing conversation with Central Office. The consultant for the facility was given conflicting information. Now there are more facilities that have disclosed not being able to meet this state regulation. How does the state want us to handle these facilities?
#2 - Relocating PBR Sources – Mike Hopkins
After hearing about the results of the portable source discussion during the Air Permitting Live call, I decided to look more closely at the rules. I was also thinking this was an issue concerning generators but found out later that this had to do with a Shelly non metallic mineral processing plant. After reviewing the existing rules and pondering this for some time I came to the following conclusions:
1. The non metallic mineral processing plant PBR was written to cover several types of portable plants including stone and gravel plants, portable crushed stone plants (31-03(A)(4)(d)(1)(b)) and portable soil screening plants (31-03(A)(4)(d)(1)(d)).
2. The rule does not have any portable source relocation language to tell permittees that they need to notify us when the plant is relocated.
3. Because the rule does not describe relocation language, it is likely that many permittees are unaware that they need to do a relocation notice prior to moving one of these plants.
4. We can argue that the relocation language in 31-03(A)(1)(p) or 31-05(H) applies to these sources, however, because the relocation language is not included in the rule, it may be difficult to convince a court that these sources are required to go through the relocate procedures.
5. It is unclear to me at this point if there is a strong need to require a portable non metallic mineral processing plant to notify us when they want to relocate. It appears we have issued just under 100 on these state-wide. I am not sure how often they need to move. I am also not sure if we tend to have citizen concerns when they move.
Based on the above, I do not think we should currently require portable non metallic mineral processing plants to go through the relocation process. However, I do think we should further evaluate this situation to determine if the relocation process is needed for these plants. As such, I suggest we add this topic onto the next P & E Committee meeting for discussion. (It also appears to me that the other PBRs are not portable sources. We should also discuss the other source types concerning portability.)
If, based on further discussion, we decide we need the relocation process to apply to these facilities, I think we will need to modify the rule before we require it. If we decide portable stuff is not needed, then we should issue some guidance that describes the fact that it is not needed.
#3 – Can powder coatings be used in daily volume weighted average VOC content calculations for compliance with OAC rule 3745-21-09(U)(1)? - Chris Clinefelter (RAPCA)
An emissions unit consists of a of wash process, liquid coating booth, powder coating booth and drying/curing oven all on a common conveyor line. Some parts are processed by coating with powder on the first loop then liquid coating in the second loop on the conveyor, with the parts never being removed from the line. The company has asked if they can include powder coatings that have no VOC solvents in the daily volume weighted average VOC content calculations for the liquid coating booth.
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